Minister of Trade Regulation No. 37 of 2025 (“MOT Reg. 37/2025“) introduces amendments to Minister of Trade Regulation No. 16 of 2025 and sets out updated policies and arrangements governing imports into Indonesia. The regulation was enacted on October 22, 2025, and reflects the Government’s ongoing efforts to recalibrate trade policy in response to evolving global trade dynamics and domestic economic priorities.
The primary objectives of this amendment are to enhance legal certainty, streamline and simplify import procedures, and strengthen the effectiveness of import supervision and control. By refining existing provisions, the regulation aims to create a more transparent, efficient, and predictable import framework that supports sustainable trade growth and enhances Indonesia’s competitiveness in the international market.
This article looks at key changes under MOT Reg. 37/2025.
Change of Importer Identification Number (API-U to API-P)
Article 8 of MOT Reg. 37/2025 introduces detailed procedures for changing the status of an Importer Identification Number (Angka Pengenal Importir or “API”), as recorded in a company’s Business Identification Number (Nomor Induk Berusaha or “NIB”). Specifically, the regulation addresses situations where a company seeks to convert its General Importer Identification Number (“API-U”), which allows the holder to import finished goods for trade purposes, into a Producer Importer Identification Number (“API-P”), which permits the importation of raw materials and semi-finished goods for manufacturing.
MOT Reg. 37/2025 retains the existing API framework, under which a company is permitted to hold only a single API, whether an API-U or API-P. While a company may convert its API-U into an API-P, conversion from an API-P to an API-U is not allowed.
Under the revised framework, the conversion process is now done electronically through the Online Single Submission (OSS) system, replacing the previous manual verification process administered by the Ministry of Investment/Indonesia Investment Coordinating Board (BKPM). The validation stage is carried out through the Ministry of Trade’s electronic trade licensing and monitoring platform, INATRADE, which is fully integrated with the OSS platform.
The regulation also introduces specific documentary requirements to support the conversion process, including certification letters and surveyor reports. Once the conversion from API-U to API-P is approved, the company’s existing import permit is automatically revoked electronically.
Revocation of Importer Identification Number (API)
Article 8A of MOT Reg. 37/2025 also introduces a new provision governing the revocation of an API. Under this provision, revocation may only be initiated by the importer and may be carried out only once.
To proceed with revocation, importers must submit an electronic declaration through the OSS system, confirming that they are no longer conducting any import activities. Once the revocation takes effect, all import permits and related approvals associated with the API are automatically deactivated.
The regulation draws a clear distinction between the treatment of goods imported under different types of APIs. Goods imported under an API-U may still be traded even after the API has been revoked. By contrast, goods imported under an API-P may not be traded, either before or after revocation.
In essence, Article 8A establishes API revocation as a one-time, irreversible process, while goods clarifying the post-revocation treatment of imported goods based on the importer’s classification.
Adjustments to Verification and Technical Inspection
Article 29 of MOT Reg. 37/2025 refines the framework for the verification and technical inspection of certain imported goods, particularly those related to safety, health, and environmental protection.
Under the amended regime, verification is no longer carried out in the country of origin. Instead, inspections are conducted at bonded logistics centers, free trade zones, and free ports within Indonesia, allowing for closer regulatory supervision and more effective compliance monitoring once goods enter Indonesian territory.
The regulation also tightens control over surveyor reporting. Each surveyor’s report is now valid for a single shipment or release of goods only, reinforcing accuracy and accountability in the verification process. All surveyor reports must be submitted electronically through the INATRADE system and are automatically transmitted to the Indonesia National Single Window (SINSW) for integrated oversight.
In addition, the amendment introduces expanded mandatory data requirements, including the HS Code, port of loading, bonded warehouse identification (TPB), and KITE (Import Facility for Export Purposes) details. These additional data points are intended to enhance the transparency and traceability of imported goods.
Conclusion
The amendments introduced under Minister of Trade Regulation No. 37 of 2025 underscore the government’s commitment to establishing a modern, integrated, and transparent import management framework. By adopting a comprehensive electronic system that connects and harmonizes various import-related information platforms, the regulation aims to improve administrative efficiency while reducing bureaucratic barriers.
This integrated approach not only simplifies licensing and approval processes but also enhances legal certainty for importers through more consistent data management and verification mechanisms. At the same time, the expanded use of data collection and analytical tools enables the government to strengthen monitoring and compliance, while supporting the development of evidence-based trade policies.
Overall, this reform marks a significant step toward a more efficient, transparent, and accountable import control system that aligns with Indonesia’s broader goal of fostering a fair and sustainable trade environment. (2 February 2026)
For more information, please contact:
Febri Ariadi, SSEK
FebriAriadi@ssek.com
